Updated: Sep 14, 2021
For this solution showcase, I was joined by Andrew Pullman, CEO of PeopleClear, the company behind PeopleClear SMCR.
Nine questions and plenty to discuss so let's get started!
I'm an English speaking alien who has just landed on earth. Explain to me what your solution does in an easy to understand way (preferably fewer than 100 words).
PeopleClear SMCR is a user friendly technology solution helping firms manage the Senior Management and Certification regulatory processes in the UK. All financial services firms have to demonstrate to the regulators how their firm is run and who does what. The firm’s managers are accountable for their assigned functions and the decisions they make and ensure that all their key people are assessed as fit, proper and competent annually, and throughout the year.
PeopleClear enables clarity of the process, outcomes and evidence to support these important management decisions. A key element is the easy-to-use reporting capability of the system.
What are the top 3 challenges that your solution helps firms to overcome?
Managing the firms functions and responsibilities – SMCR is applied depending on firm type and the definitions are embedded in the FCA website and handbook. PeopleClear SMCR has translated these requirements and made it easy for any firm to allocate the relevant functions & responsibilities. A clear and graphical Management Responsibilities Map can be generated easily at any time and a historical trail saved.
Managing the Certification process – a user friendly tool that all senior managers and certified people can access to upload evidence, enabling certification of key people. Relevant reports support the certification process
Regulatory References – it is a regulatory requirement to provide a clear reference of an individuals regulated activity. PeopleClear SMCR has all the relevant information, and the reference can be generated quickly and easily. It is also a requirement for firms to update any references should new evidence come to light. PeopleClear SMCR makes the process of tracking and updating references straightforward.
What are the main risks if firms fail to tackle these challenges?
Failure to manage and communicate the senior management responsibilities with clarity, either internally or more importantly to the regulators; this could lead to sanctions and heavy fines/claw back as well as reputational damage. Possible custodial sentences for non-compliance of the SMCR;
Poor quality of certification decisions / process which could lead to individual or organisational sanctions by the regulators; ultimately firms could cease to be regulated if they do not demonstrate strong regulatory processes;
Incorrect reporting could force investigations by the regulator leading to individual and organisational sanctions. Poor reporting also suggests poor overall management of the business.
Think of PeopleClear SMCR as an insurance policy against most of these risks!
What makes your solution different from the competition?
The key differentiators of PeopleClear SMCR are:
Laser focus on the senior management and certification processes, which are the key people related elements of the SMCR;
User friendly and intuitive design of the system and efforts to de-mystify rather than over complicate;
PeopleClear SMCR was created by practitioners for practitioners, rather than being technology or purely compliance driven; purpose built to address SMCR;
Our solution is scalable and is suitable for firms with a just few regulated individuals or hundreds;
We have ISO 27001 certification and use the Amazon QLDB managed ledger database to ensure immutable data security.
I'm a prospective client, explain (in simple terms) the typical buying process I can expect for your solution.
Firstly, you can get a good overview of what we offer on our website – www.peopleclear.co.uk – including a short video of how the system works;
Next, we carry out a short diagnostic discussion with you to establish what your SMCR needs are, and which aspects of PeopleClear SMCR are most useful to you; this will include a short demo of the system;
If you want to proceed, we tailor the onboarding process for your technology setup and any specific requirements.
Our onboarding team will provide training and guide you through the process to add administrators and upload your firms information.
Pricing is based on the number of Senior Managers and Certified Persons across the firm – administrative access is FREE – using a SaaS model; typically we would agree an initial 3 year contract.
How do you feel about the way that financial services regulation is changing?
Regulation is not going to go away. With the increasingly dispersed nature of workforce’s post Covid there will be an even more focussed effort to ensure that people are fit, proper and competent to do their jobs in a regulatory safe way.
Regulation is also much more than just ticking the right boxes, it is all about creating and maintaining the right culture within financial services firms. The focus of the FCA and PRA is now all about the holistic way firms are being led, and managed, and how they can demonstrate tangibly how they are creating those cultures.
What is the one piece of advice you would give to firms facing today's regulatory landscape?
Take the regulation seriously as it will underpin the success of your business. The old adage that it is your people who make an organisation succeed or fail is absolutely true in financial services, and their regulation is a key part of that.
Any development plans that you would like to share?
Technology is advancing apace and is critical to the successful management of a regulated firm. Technology solutions will need to develop and adapt, which is why PeopleClear SMCR is already developing the next stage which leverages machine learning and AI to identify change that impacts the firm’s SMCR and analyses data to minimise risk and flag issues before they occur.
Finally, could you take a look at the 4 Pillars of an SMCR solution https://www.therulesconsultancy.com/the-four-pillars They all matter but I wonder if you could rank them 1-4, according to their importance, in your experience.
All of these pillars are important but we would put engagement top as we feel that getting users engaged and owning SMCR is vital and a solution should enable that engagement.
Many thanks for your time, Andrew. Don't forget to come back and give us an update soon!